Sarah Bean is a registered representative with NewWave Investments, a family of mutual funds. She has recommended one of NewWave’s funds to a client and given him a prospectus. The prospectus provides information about the fund’s breakpoints and indicates that an investment of $25,000 or more will lead to a reduced front-end load. The prospectus also clearly explains the details of a letter of intent. Sarah’s client invests $23,000 in the fund then and there without even opening the prospectus. Has Sarah violated any of FINRA’s rules of conduct?